JCCP Recommends Complete Ban On Remote Prescribing Of Botox In New Guidance

Who Is The JCCP?

The JCCP is a ‘not for profit’ UK charitable body charged with the responsibility of voluntary ‘self-regulation’ of the non-surgical aesthetic sector in the four UK countries. GlowdayPRO’s expectation is that when non surgical aesthetics licensing laws are implemented, the JCCP will become the de facto regulator - the organisation has been working tirelessly behind the scenes to bring about change in the industry and is a driving force behind the licensing regime’s implementation.

What Have They Said?

The JCCP identifies that the cosmetic sector is a law unto itself in context of the standards expected in medicine for prescribing, where competence is married within a robust framework of oversight and guidance. In contrast, in the non surgical aesthetics market, ‘prescribers usually work independently and without immediate oversight, frequently compounded by the commercial environment in which they work. Under these conditions there is a tendency for transparency of practice to be opaque, making enforcement by professional regulators and others more difficult.’

It looks as if the JCCP is making moves to ensure that this gap is closed and there is more regulatory oversight, and it, in coordination with other bodies including the GMC, NMC and GcHp has set down their decision not to endorse or permit the remote prescribing of any prescription medicine when used for specifically for non-surgical cosmetic treatments.

How Will This Impact You?

You might not think this is a big deal. You’re either already a prescriber or you ensure your prescribers work with your patients independently and face-to -face, as this is mandated by your statutory body.

As well as clearly being the right thing to do to help protect patients and professionalise the industry, it will impact many non-medics who have heavily relied on remote prescribing.

And, assuming this become a key component of licensing requirements, it may have a massively positive indirect impact on your business.

How?

Firstly, the JCCP puts a lot of emphasis on the responsibility of the prescriber, that “they must exercise their professional and clinical judgement, have adequate knowledge of the patient’s physical and psychological health status and be satisfied the medication serves the person’s needs .. the prescriber must be familiar with the patient through an initial face to face consultation and diagnostic assessment of the patient’s suitability for treatment. This applies to the routine/planned administration of medicines that are used specifically for cosmetic purposes, such as botulinum toxins, injected local anaesthetic or topical adrenaline, and the emergency use of medicines such as hyaluronidase. Prescribers should not therefore prescribe such medicines by telephone, video link, online or at the request of others for patients whom they have not examined personally.”

Will prescribers be more reluctant to work with non-medics, who don’t tend to complete informed consents in the same way medics do, nor have the same approach to BDD? Will they want to travel to beauty salons and hairdressers for their clinics? Will they be more 'on the hook’ for complications?

If prescribers do choose to work with non-medics, it is likely they will increase their fees and non-medics will have to pay more for their prescriptions. This could be detrimental to their business (particularly if dermal fillers become a prescription-only product).

Therefore it may hopefully prevent non-medics from offering these treatments and the proliferation of cheap deals and artificial suppression of prices across the industry.

Small Steps, Big Impact

While we don’t believe that the Government will ever restrict non-surgical aesthetic treatments so that only the medically-qualified can administer them, chipping away at the ecosystem which enables non-medics to offer treatments is a good step forward. If licensing requirements ban remote prescribing, if dermal fillers are made prescription only, if there is a minimum training standard required and if clinic spaces have to be CQC (or equivalent) compliant then it will have a big impact. Not a perfect impact, and it would be much easier to follow other countries and just medicalise non-surgical cosmetic treatments, but we are where we are are and we’ll take it!

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